Quiroz v. Nalus
REVERSALFacts
1. The Antecedents: The underlying dispute involved a contractual breach by Ramon R. Nalus, leading to a claim for damages by Gloria F. Quiroz. The trial court had initially awarded damages, but this was deleted by the Court of Appeals for lack of basis, holding that damages in a judgment on the pleadings require proof of their factual basis and causal connection to the act complained of. 2. Procedural History: The Court of Appeals deleted the trial court's award of damages in its Decision dated September 20, 2018, and affirmed this deletion in a Resolution dated January 11, 2019. Subsequently, this Court, by Resolution dated March 11, 2020, denied Quiroz's petition, affirming the Court of Appeals' decision. Quiroz then filed a motion for reconsideration of this Court's denial. 3. The Petition: In her motion for reconsideration, Quiroz sought to reinstate the trial court's award of damages without further proof, citing cases where damages were upheld in judgments on the pleadings due to admitted allegations. Alternatively, she prayed for the case to be remanded for presentation of evidence on her damages, given the impossibility of Nalus returning possession of the property. The respondent, Nalus, argued that damages are not deemed admitted even if not specifically denied and require proof. This Court, in its Resolution, partially granted the motion for reconsideration, modifying the previous denial and remanding the case to the Regional Trial Court for reception of evidence on the precise extent of damages claimed by Quiroz.
Issue(s)
Whether the award of damages in a judgment on the pleadings, absent specific denial, should be upheld without further proof of their extent. Whether the case should be remanded for reception of evidence to determine the precise extent of damages.
Ruling
The Supreme Court resolved to partially grant the motion for reconsideration and modify its previous Resolution dated March 11, 2020. Civil Case No. 14-131611 is remanded to the Regional Trial Court, City of Manila, Branch 52 for reception of evidence on the precise extent of damages Gloria F. Quiroz claims to have sustained due to the contractual breach of Ramon R. Nalus.
Ratio Decidendi
On the issue of whether the award of damages in a judgment on the pleadings, absent specific denial, should be upheld without further proof of their extent: The Court ruled that while a contractual breach may be deemed admitted if not specifically denied in a judgment on the pleadings, the resulting damages are not automatically admitted. Citing Swim Phils., Inc. v. CORS Retail Concept, Inc. and Raagas v. Traya, the Court emphasized that actual damages must be proved, and courts cannot rely on speculation or conjecture. The extent and pecuniary value of actual damages require actual proof. Therefore, even if the breach is admitted, the plaintiff must still adduce evidence to establish the exact extent of damages. The Court clarified that the cited cases of Santiago v. Basifan Lumber Co. and Tropical Homes, Inc. v. CA are not on all fours because in those cases, there was either a stipulation on the value of damages or an admission on the reconstructed payment scheme, which is not present in the instant case. Consequently, the presentation of evidence is necessary. On the issue of whether the case should be remanded for reception of evidence to determine the precise extent of damages: The Court found the motion for reconsideration meritorious. Applying the principle that damages must be proved and citing Swim Phils., Inc., the Court held that in the higher interest of substantial justice, the case ought to be remanded to the trial court for the reception of evidence to determine the precise extent of the damages claimed by the petitioner. This is to ensure that the petitioner has the opportunity to prove her claim, especially since the respondent could no longer comply with the obligation to return the property.
Main Doctrine
In a judgment on the pleadings, while a contractual breach may be deemed admitted if not specifically denied, the extent of damages arising therefrom is not automatically admitted and requires presentation of evidence, unless there is a stipulation or admission on the amount of damages.